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Submission to the Otago Regional Council 2014 Draft Regional Public Transport Plan
Submission by Bus Go Dunedin – Bus Users Support Group Otepoti-Dunedin to the Otago Regional Council's Draft Regional Public Transport Plan 2014 Introduction Bus Go Dunedin is an advocacy group for public transport in Dunedin. We work to gain a clear understanding of best public transport practice, to gather the views of bus users and to represent them to providers and operators of public transport. Our decisions are made by consensus at meetings open to the general public. We regard all Dunedin bus users as equally empowered to influence and approve our representations on behalf of users. The 2014 draft Plan is the best public transport plan the Otago Regional Council has ever produced. We are particularly impressed wtih the skill and care with which Council staff have applied the NZTA's Passenger Transport Operating Model to our local bus network. Bus Go Dunedin regards this draft plan as a constructive step towards handing Dunedin public transport management over to the Dunedin City Council in the best possible state. We also wish to stress that our preference for city-led management is in no way a criticism of the regional council and its staff. We appreciate the ORC's willingness to consult with us, and to listen to our suggestions for a better bus service. And we're particularly gratified to see our suggestions acted upon. Bus Go Dunedin supports all parts of the Plan which we have not commented on. Summary of requested changes to the plan (to come) Requested changes to the plan This part of our submission will take the form of page-by-page requested changes to the Plan. Minor quibbles are listed along with major objections. Major changes requested in this section are addressed in detail later in the submission. All parts of the plan: Many chapters of the plan present “policies” written in bold, while in other places, assertions as to future practice and requirements are stated less clearly, as goals, strategies, as data in tables. We would like the Plan to clearly mark all policy; this would lead to roughly a doubling of the numbered policies. We suggest that each policy be given a chapter and policy number (as Policy 1.1 to Policy 9.999) We want it to be clear what is policy and what is general expanatory text. We want to be able to measure actual performance against this Plan's clearly stated policy. Where the Plan makes an statement about required performance which is not marked as Policy, we will from time to time request this be elevated to a numbered policy point. P12 “representatives of groups...” Please name the groups. P27 Total Mobility: Please make “we will implement these policies” as a numbered Policy in itself. P29 Policy 8, Policy 9: Bus Go Dunedin requests a change to these policies. We will present this in a later part of this submission. P30: Tables 4 and 5: please identify these as Policy P30 table 5: Please amend heading to read “Long distance coach stops” not “bus termini” and under Dunedin City include existing coach stops at Botanic Garden, Great King St North, Countdown Cumberland St, forecourt of Dunedin Railway Station. Bus Go Dunedin also desires coach stops at King Edward St Overpass, Caversham Valley, Burnside, Abbotsord interchange, Mosgiel interchange. P38 “trialling a student discount” This is now ORC policy in Annual Plan; please amend to read “introducing a student discount” P40 Table 5: (Note there is already a table 5. Better perhaps to number tables by chapter) “Proposed response” please elevate to numbered Policy. P44 What we want to achieve (and table 6 on P45): Please elevate these goals, objectives, measures and targets to numbered Policies. P45 Table 6: “Fully accessible public transport” Please change to “ Fully accessible buses” and insert new row “Fully accessible bus stops” | “Proportion of bus stops with correct entry and exit of bus to stop, kerb height and safe pavement surface” and give current performance and future target (which latter Bus Go hopes will be “excellent”) P45 Table 6 “Idling of buses does not...” Please amend to read “...public health or amenity values”; amend next cell to read “...limits for health and does not attract complaints” P45 Table 6 Please add new row “Buses do not clutter city centre” | “Buses are scheduled and operated in order to arrive 'just in time' for each departure from the city and do not need to be stored downtown in large numbers for long periods while they await their next departure” and give current performance and future target (which latter Bus Go hopes will be “excellent”) P47-48: Please upgrade all objectives and principles in this chapter to numbered Policies. P48 Access and mobility principles: Please add new point “accessible design standards of bus stops with correct entry and exit of bus to stop, kerb height and safe pavement surface” P48 Efficiency principles “scheduling that makes good use...” and “scheduling that avoids...” - Please add “and operating practice” to read “scheduling and operating practice that makes good use...” and “scheduling and operating practice that avoids...” P50-55: Bus route maps We will give a critique of the proposed routes later in this submission. P57 Table 7: Bus Go Dunedin objects to the severe reduction of initial weekday frequency of 60 minutes off peak for Belleknowes and Brockville and also seeks adjustments to the frequencies of Waverley, Mosgiel and Northern Services. All these will be detailed later in this submission. P62: Bus Go Dunedin opposes some of the changes to electronic zones and fares and will request changes to the proposed cash fares. All these will be detailed later in this submission. P64-65: Bus Go Dunedin has views on the city bus hub, superstops and real-time information which we will detail later in this submission. P67 Services important to the wider public transport network: Bus Go Dunedin asks that the regional council go beyond merely “acknowledging the importance” of inter-regional, exempt and excluded public transport, but rather give public and political support (not necessarily money) to these services, for example: a page in the public timetable summarising these services, links from the council website, inclusion in the Journey Planner. Bus Go Dunedin also desires coach stops at King Edward St Overpass, Caversham Valley, Burnside, Abbotsord interchange, Mosgiel interchange. P69: Principles of the unit design: upgrade to Policy P70-71: Dunedin PTOM units: Bus Go Dunedin asks that there be two or three very small units, operable by a small “mum and dad” bus company. We intend no criticism of large corporate bus companies but we wish to record the well-deserved reputation for friendly service achieved in the past by smaller firms such as Otago Road Services, Newtons Coachways, Peninsular Motor Service and Mosgiel Coach Services. The latter introduced several innovative electronic fare options on their new Concord service including student fares and weekly and monthly passes, as well as park & ride; most of these disappeared when they became part of a larger company. A variety of PTOM unit sizes is the best way to achieve the nurturing of innovation and close personal service. We note that there would be nothing stopping large bus companies sucessfully tendering to operate small units. P73 Policy 12 (a) “without services tailored to different customers”: We note that this policy is at odds with the Policy 8's provision for exempt and excluded services; for example school buses are certainly “tailored to different customers” - we ask that the Plan text explain this in a preamble to this Policy. P74 7.2 Network structure... “ORC will implement these policies”:needs in itself to be a Policy. P75 Policy 18: add “(e) Bus stops to meet design specifications in 'Guidelines for public transport infrastructure and facilities' NZRTA 2014 P76-84 Standards I-XIII: restate all these as numbered Policies. P76 Standard I (a) “peak periods: at least 10 passengers per trip” Bus Go Dunedin objects to this provision and wonders if it is written in error. At peak periods it is common for trips in one direction to be full and then run empty on the return to pick up the next load. We wonder if it was intended that peak trips therefore need to have 20 people on all directional commuting loads. We ask that Standard I (a) be amended to read “peak periods: at least 10 passengers per return trip” P77 Policy 19 (a) “defining quality standards”: Please add “... for buses, bus stops, bus routes and operation of services” P77 Policy 21: This seems to be written as a catch-all disclaimer to exonerate ORC's contractors. Please rewrite this as a list of what contractors “are” liable for, what “is” in their control. This Policy should also mention that the Consumer Guarantees Act gives passengers rights as consumers. P77 Policy 22 (b): Please add a note that standing on an urban bus is legal and safe, if rather uncomfortable. P78 Standard II: Bus Go Dunedin objects to the 59 second tolerance allowing early departure from timing points. We ask that this tolerance be amended to read “0 seconds to 6 minutes and zero seconds after the departure time” Bus Go Dunedin accepts that bus services in order to be operationally efficient, safe and affordable may often run slightly late, but we insist that early running should be clamped down on wherever it occurs. We also ask that the following text be added: “en-route timing points should be scheduled, and contractors should operate buses in traffic, so that the bus arrives at the timing point 'just in time' with no undue interruption to the continuation of the journey, except to await connecting passengers.” P79 Policy X: Please add text “Prams containing resting or sleeping children should be recognised as a mobility aid in use by a passenger, not viewed as an obstruction to other passengers, and drivers shall allow prams containing children to occupy any part of a bus where passengers are allowed to stand, provided that the pram can be easily moved (off and back on the bus if necessary) as required to allow safe movement of other passengers” P80 Policy 25: We support the adoption of 'Requirements for Urban Buses' with an exception for rear doors. We will detail this matter later in this submission. P80 Policy 27 “0-10 years... Equal or greater than 50%”: Bus Go Dunedin opposes this policy on grounds of affordability. A bus is a bus. We desire buses of a high standard of cleanliness, safety and comfort, but we do not accept age (within the proposed 19-year age limit) as a determinant of bus quality. Any bus meeting the NZTA RUB is acceptable. We understand that the RUB gives 50% 0-10 years as a “desired fleet profile ” not a requirement. There are good reasons to operate old (cheap) buses, especially to allow a reserve fleet for peak or emergency use. Bus companies will use new buses according to their needs to lower running costs. P82 Policy 29 (g): Bus Go Dunedin opposes the proposed changes to electronic fares and zones and seeks changes to the proposed cash fares. We will detail these matters, along with transfers, later in this submission. P82 Policy 29 (h): Please list all the mandatory concessions, not just child fares. P84-85 Provisions for Contracts A-D: Please re-state these Provisions as Policies. P86 Policy 31: Replace with “Public transport infrastructure meets the design standards in 'Guidelines for public transport infrastructure and facilities' NZTA 2014” P86 7.7 “We will implement these policies through” - Please re-state the implementation as itself a policy. Please add policy points as follows: (a) timetable booklet to be designed in consultation with users to be clearly legible (b) delivery of booklet to households © hours of operation of call centre (which Bus Go would like to be all hours of operation (d) call centre target waiting time P87 Policy 34 (b): Please make it clear that ORC is to provide timetable booklets which contractors should make available on buses and that contractors provide timetables of their own indvidual routes on their buses at their own cost. P92 Table 17: Please elevate this table to the status of Policy. P94-95 Policy on significance: Please present the policies here as numbered policies. P94 Non-significant variations: Add “and user groups” to each point to indicate that user groups should be consulted. P97 Table (un-numbered): Please make clear that this table is Policy. Please add “and user groups” at each place where it is stated that ORC will consult with operators or local authorities. In the third row of this table, Bus Go Dunedin would support a regime of contract-lengthening as an incentive where performance targets are being met. Lengthening contracts reduces disruption to users, contractors and their employees and is a worthy reward for good performance. P99, top “We developed this assessment...”: please change “Blind Foundation” to “Royal New Zealand Foundation of the Blind”, “Bus Go Group” to “Bus Go Dunedin – Bus users support group Otepoti Dunedin”, “VICTA” to “VICTA - Visual Impairment Charitable Trust Aotearoa NZ”, NZTA to New Zealand Transport Agency P108 St Kilda to halfway Bush and Brockville and return: change “20 minutes” (a very rarely applied peak frequency) to “40 minutes” to reflect the usual frequency. P124 Appendix 6 table 23: Please indicate that this table is Policy. Please add in the row “Public satisfaction..” the source “Complaints and compliments to contractors and to the ORC and in the media about bus services” Please add in the row “Indicator of reduced emissions” the source “Complaints to ORC, to contractors and in the media about bus exhaust” destos route numbers 0xx branding (aff, op eff, transfer of fleets) coke bus read the bloody sign hub and superstops Doors P80 Policy 25: We support the adoption of 'Requirements for Urban Buses' with an exception for rear doors. Christmas etc P29 Policy 8, Policy 9: Bus Go Dunedin requests a change to these policies. We believe these Policies could bring about the end of the Otago Heritage Bus Society's Suburban Rumbler public transport service on Christmas, Good Friday and Easter, when no other puvblic transport is operating. That service operates under exactly the same regulations and levels of safety as the propoed exempt “ii. School bus services not contracted to the Ministry of Education or ORC” (sometimes using the same make and model of bus). Bus Go Dunedin supports the continuation of Otago Heritage Bus Society's Suburban Rumbler and requests that Policy 8 be changed to include “iii. Other services operating within an area normally covered by an integrated public transport network on days when this network is not operating” and that Policy 9 be amended to allow legally operable heritage vehicles providing an earlier standard of amenity including their noise and exhaust output within legal limits. Route by route analysis Bus Go Dunedin supports the plans for through routes linked via a central hub. We also support the move to main roads not back streets as being in the long-term interest of the development of the bus network. We accept that the city's arterial road network generally follows the same geographical form as is needed for a public transport network (radial from a hub with the odd orbital route) We therefore support the move generally to place buses on the main road network. In particular we support the following statements in the Plan: P40 “Public transport will always be slower...this difference can be minimised by having more direct routes...” P47 Network design principles “routes that are direct as possible without unnecessary impedance, deviation or variation” P48 Patronage principles “routes designed to provide acceptable travel time compared to other common travel modes” P49 “...use main roads and avoid using small residential streets except where they form a safe route to turn the bus at the outer end of a journey.” Unofficial design approaches used by council staff We note there are some features shown in the maps of the Plan's proposed network that are not backed up by any policy in the Plan's text. There appears to be unofficial design rules indicating a move away from looped services and that once out of the CBD, routes shouldn't converge or cross each other in the suburbs. Both these biases have affected the layout of the proposed network. This can result in some irritating “change for the sake of change” of well-established service patterns. Bus Go Dunedin requests that these undiocumented unofficial design biases be removed from the proposed network design. Loops Loops allow a bus nearing the end of its journey to turn around gradually in a way that does not interrupt its journey. It should be realised that it costs about 50c to stop a bus and start off again, so it can be seen that a situation where passengers get off at the same time as others are getting on is preferable to a situation where the last several stops on a route are only used by those getting off, the bus does a U-turn, then the first several stops are only to board passengers. If the bus has to turn around anyway it might as well do something useful and cover a couple more streets. There are two kinds of loops. Two-way loops involve a bus service travelling in both directions along a circular route. Examples in the existing bus service include Brockville-Halfway Bush (with which we disagree as those suburbs are far apart and the connecting road has very few residents) and Corstorphine (which we support as the layout of that suburb lends itself to such a loop). One-way loops are supported in the Plan's text (P49) “...use main roads and avoid using small residential streets except where they form a safe route to turn the bus at the outer end of a journey” We feel it could be applied in a few more places. We give examples below of routes where one-way loops could be added to improve operational efficiency and service quality. Convergence/intersection We disagree with any notion that once out of the CBD, routes shouldn't converge. It is not a Policy anywhere in the Plan and it would negate many benefits of the planned change to a transfer system. The more routes interconnect, the more connecting journeys are enabled. Route-by-route analysis and critique In this part of our submission we wish to describe any concerns we have with changes to routes, with suggestions for adjustment to the Plan. We will not generally name routes by their proposed new number, as the assignment of paired suburbs and route numbers is arbitrary, a procedural matter and subject to change. Please note that we support the design of any planned routes that we do not mention below. Brockville Bus Go Dunedin opposes the huge cuts to the Brockville bus service being proposed. At present Brockville is served by a bus every 40 minutes. The list of “network essential services” (P57) cuts this to every 60 minutes in the off-peak. The proposed removal of all direct services to Brockville and combination of Brockville with the Belleknowes service represents a further service cut. Buses travelling via Belleknowes would take a huge time penalty before they even begin to serve the suburb of Brockville. Of all the bus service plans described in the Draft Plan, Brockville would receive the greatest reductions in service. It would end up with the equal-worst bus service of any city suburb, as its service frequency would be reduced (along with Belleknowes) to the same level of Waverley. The social justice issues surrounding this proposal demonstrate its unfairness. For over 20 years, Brockville residents have had to "pay their own way" — unlike almost all other parts of Dunedin, they have not had any Government or Regional Council subsidy for their daily bus service. This is in spite of their being one of the more socio-economically deprived areas of Dunedin, with low incomes and low car ownership. See for example the data here: http://www.mashblock.co.nz/search/results#/area-unit/brockville Brockville's physical isolation from the city centre with steep hills makes other alternative transport, such as cycling, unavailable to many people. To add an extra unfairness to the reduction in bus service, the Draft Plan proposes to upgrade the adjacent suburb, Halfway Bush, to a 15-minute frequency. At present, both suburbs have an identical bus service and a broadly similar social profile. We do not understand how this decision could be arrived at. Present ticketing data would not provide sufficient separation of journeys to and from Brockville and Halfway Bush on the present combined service for the council to make a fair decision so heavily weighted against one part of the present route. The proposed routing of Brockville services via Belleknowes breaches the following parts of the Draft Plan: P40 “Public transport will always be slower...this difference can be minimised by having more direct routes...” P47 Network design priinciples “routes that are direct as possible without unneccessary impedance, deviation or variation” P48 Patronage principles “routes designed to provide acceptable travel time compared to other common travel modes” It appears the frequency cut has arisen from the policy that routes should run through the city centre to another suburb on the other side of town. Having picked Waverley as Brockville's paired suburb, the writers of the Draft Plan saw fit to drag Brockville down to Waverley's service frequency. We support the policy of a through-route structure but we do not support the route structure being used to lower the frequency on both ends of a newly-joined route. Bus Go Dunedin requests that Brockville be served with a similar frequency to Halfway Bush with a direct route via Stuart St, Kaikorai valley Rd and Brockville Rd. We suggest that Brockville services should end with a one-way loop on back streets of upper Brockville in keeping with the design principle (P49) “...use main roads and avoid using small residential streets except where they form a safe route to turn the bus at the outer end of a journey” Belleknowes Bus Go Dunedin opposes the reduction of frequency for Belleknowes. We request that this suburb continue to be served half-hourly. We support moving this route on to main roads. We recommend the extension down Stone St be deleted; this has not become an important feature of the existing route in the few years it has operated as the street has few residences. We oppose the removal of service from the Arthur St area. We think a one way loop including this area is a fair, accessible and affordable design for a Belleknowes service in keeping with the "main roads" policy. Bus Go Dunedin requests that Belleknowes be served by a one-way "Belleknowes Loop" service up Rattray St, City Rd, Ross St, down Kenmure Rd and Mailer St to Mornington, then down Hawthorn Ave and Maori Rd to Arthur St. See this Google map: http://goo.gl/maps/T1S8U Waverley We believe an hourly frequency is not sufficient to provide Waverley with a quality service but we note that this is not a reduction from the present service level. We would support any call by Waverley users for an improvement to their off-peak frequency to half-hourly. Waverley could be served very frequently as part of a large Waverley-Shiel Hill two-way loop of alternating clockwise and anticlockwise services. Shiel Hill See Waverley above. If the two suburbs were looped together at the same time that the increased frequency is applied, a situation whereby no-one is worse off and everyone is better off could be achieved. See this Google map: http://goo.gl/maps/Cdylx Corstorphine and St Clair Park Bus Go Dunedin opposes the separation of this route proposed in the Draft Plan. This would be a further meddling with the services to this suburb and would follow the previous July 2013 service changes which had a disasterous effect on passenger numbers. LYNLEY! The users of the Corstorphine made clear their desire for a reversion to the 2013 route in a recent popular petition. We note that the present service allows all parts of the suburb to chose between access to South Dunedin and the opportunities there for low-cost shopping as well as the faster route to town via South Rd. We note that the Draft Plan indicates a higher frequency for the proposed Corstorphine (only) service but we fail to see why this portion of ths suburb is proposed to have a higher frequency than the Kew-St Clair Park service. If the service were to remain as at present we note that the present deviations through St Clair Park and Stenhope Crescent would clash with the Draft Plan's state aims of “main road” not “back street” service. We invite the regional council to investigate this matter further and we propose a solution below where we discuss the Concord route. Bus Go Dunedin requests that both sides of Corstorphine continue to be served by a two-way loop service. Kenmure Bus Go Dunedin opposes the extension of the Kenmure route to Concord. We ask that it instead end in a large one-way loop following the design principle (P49) “...use main roads and avoid using small residential streets except where they form a safe route to turn the bus at the outer end of a journey” using Elgin Rd, Barr St, Kaikorai Valley Rd (west side to serve the College), Bryant St, Kenmure Rd, then back up to Mailer St. See this Google map: http://goo.gl/maps/IHVre Halfway Bush We support the proposed improvement to frequency. We wonder if the frequency is a little too generous as some of our suggestions for adjacent routes would provide extra journey opportunities. We support the permanent loop via Ashmore St. We question the need for the dog-leg to Ashburn Hall as conrary to some of the Plan's network design principles but we would support its retention if a genuine need can be established there. Wakari and Helensburgh These suburbs are a little challenging for route planning as they have a fairly high population but all the main roads are around the edges. Wakari 3 Hospitals Link We oppose the extension of the Wakari route (marked 6) up Centennial Ave as this breaks all the “back street” rules and is unnecessary. On the other hand most of the Wakari route needs to be in back streets as this suburb is just one big back street. So we suggest turning this to advantage and using smaller buses for a “3 Hospitals Link" via Dunedin Hospital, Moana Pool, Olveston, Mercy Hospital, Lynn St and Chapman St to Summerset Village, then up Shetland St to Taieri Rd and into Wakari Hospital grounds. We note that Wakari Hospital is a destination for some passengers with lower cognitive abilities and there was documented trouble in past years when some Wakari buses did not go to the hospital with that name. This has been remedied in the past several years as all buses carrying the destination "Wakari" have terminated close to the hospital. We request that this principle continue. See this Google map: http://goo.gl/maps/FjbDW Helensburgh We support the planned route up Pitt St via Maori Hill. We recommend a fast route from there via Balmacewan Rd. An end one-way loop for this route is ready made: Helensburgh Rd, Taieri Rd, Wakari Rd and back down Helensburgh Rd. This will increase transfer opportunities around Wakari Hospital and augment the Halfway Bush route. See this Google map: http://goo.gl/maps/id9RS Kaikorai Valley-Concord Bus Go Dunedin opposes the deletion of this route. The present Route 38 meets many of the design principles included in the Plan, as a fast route along a main corridor. It should be developed and marketed as an outer orbital route, perhaps called "The Concorde". With little increase in route mileage, the Concord route could extend the full length of Mulford St to take over the Stenhope Crescent and St Clair park extensions of the Corstorphine route, enabling the latter to become a streamlined, fast loop service (see above). The Concord route should continue to intersect with Halfway Bush, Brockville, Kenmure, Mosgiel and aditionally Corstorphine and St Clair routes to provide many transfer opportunities for the new transfer-based system. In the distant future, we envisage this route extending down Bay View Rd to Andersons Bay and Portsmouth Dr. Bus Go Dunedin request that the Concord route be retained as an orbital route and extended via St Clair Park to St Clair Beach. See this Google map: http://goo.gl/maps/oeCXr Port Chalmers and Mosgiel These two routes are not meeting their full potential as journey times are very long. We believe that any service frequency improvements to these routes be in the form of express services wholly on State Highways 1, 87 and 88 with stops at safe locations along the highways but no deviations. We support the continuation of regular parallel “slow” services along older back roads which include Roseneath, Fairfield etc. On the southern route, new highway bus stops at at King Edward St Overpass, Caversham Valley, Burnside, Abbotsord interchange, Saddle Hill and Mosgiel interchange should be built. These would also benefit long-distance coach pasengers. Some of these could be superstops to enable interchange with local routes. Bus Go Dunedin requests that improvements to the Port Chalmers and Mosgiel frequencies be in the form of regular high-speed direct express services stopping only alongside state highways with no deviations. Ridge Rider We give wholehearted support to this route. To reach its full potential, it may be a good idea to “complete the circle” and run it from South Dunedin via the back of the Railway Station and Harbourside to the University (in both directions). This route should receive special marketing to tourists as it will provide a scenic tour of the city. Stadium (route “2” on maps) Seriously? It would be better to serve the rear of the University and Otago Polytechnic. The stadium is an large-event-based venue; the proposed route would be always either too much or not enough to effectively serve that destination. We do, however, suggest that all sixteen proposed bus routes be served by special departures from the Stadium organised by the regional council and its contractors after large events there. A shuttle service from the city centre to ths stadium before events would also benefit from being organised as part of the public transport network. Fares and zones Bus Go Dunedin opposes the proposed fare structure We support the intent of the proposed changes but we feel the principle behind them is unclear. We wish to draw a distinction between cash fares, which we agree should be greatly simplified, indeed further than the Plan proposes, and electronic fares, for which we see no need for simplification, only fairness. Cash Bus Go supports a greatly simplified system of zones for cash fares. It is quite absurd for a modern bus, worth $300 000, to be held up at a bus stop while its driver is searching for a millionth of that amount to give as change on a $2.70 fare. We request that all cash fares be rounded up to the next dollar value and that electronic ticketing be encouraged. We would support a greatly simplified zone structure for cash fares, perhaps of just $4 and $8 fares ($3 and $6 for children). Transfers need not be available on cash fares. We accept that our proposed cash fare policy could lead to hardship for some passengers. But we believe that the cash fare scale should give a clear message that electronic ticketing is preferred. We believe that concerns about affordability should be addressed through changes to the electronic ticketing system, which we will explain below. We note that the industry is concerned about muggings of drivers and that a “no change given” policy may arise in future. Electronic fares Bus Go supports a system of fares reflecting the actual distance travelled for electronic card users We fully endorse all the documented advantages of a tag-on-tag-off electronic fare system, with its reduction of fraud, prevention of ticket over-running and, speeding of boarding (and therefore service speed). The Draft Plan has failed to grasp the advantages of tag-on-tag-off in its assetion that there is a need for simplicity in the electronic fare structure. With tag-on-tag-off, passengers don't need to know their destination zone, or the name of the street where they are heading. Drivers don't need to memorise zone boundaries. Passengers can even change their mind mid-journey and divert to a different destination; the ticket system will adjust their fare automatically. We assert that an electrionic system of fares does not need to be simplified, it just needs to be fair. For regular passengers, distance is the only equitable means to levy fares. The more zones thare are, the more closely the fare will reflect the distance travelled. The tag-on-tag-off system could even charge passengers per kilometre, which would be a great marketing tool as it would allow a direct comparison with taxi fares and car running costs. Bus Go Dunedin requests that there be no fewer than the present number of zones for electronic card users. Affordability Now that the bus fleet is wheelchair friendly, another barrier to many people's mobility is becoming more obvious. Bus Go Dunedin often recieves information that people are unable to afford bus travel. We hear of people who use their car because it has petrol in the tank but their GoCard is empty. We hear of people scrounging their home and family members for loose change to travel by bus on a more expensive cash fare because they can't afford the dent in their food budget that a minimum $10 GoCard top-up entails. Although we proposed above a fairly punitive cash fare scale, we feel that the electronic fare system holds great scope for assisting with affordability. We note the recent student 25% discount trial which resulted in acceptance of the lower fare level by contractors and a gradual uptake by students. We also note the continued problem people with disabilities have in getting applying for and renewing their GoCard Extra to obtain anfeel the time has come Fare innovation and value maximisation We accept the need to maintain or increase present cashflow in the industry. We feel that there is great scope for increasing use through novel marketing schemes. A general principle should be that using public transport is a rational economic decision: it's slower and somewhat less convenient than private transport, but it's cheaper. We note that while bus fares are reasonably comparable with car running costs for a single motorist, filling the seats of a car destroys bus travel's cost advantage. Examples *Concessions for an adult and three children travelling together (fare to be set lower than running costs for a car). Travel together to be determined by the group adjacently boarding/alighting on the tag-on-tag-off system. *Concessions for constant users who make a return trip every work day, such as every fifth or tenth day free, or free weekend travel for two adults and some children. The "Flybuys" or "coffee card" style points could accrue automatically as they use the tag-on-tag-off system. 21st Century fare systems Principle: with smartphones and tablets becoming ubiquitous, these technologies can be leveraged to provide a more user-friendly experience for patrons, and lower costs for service providers. * Explore options for payment via smartphone, for example with NFC, WiFi, Mobile Data or Bluetooth technology, and (possibly) an app or web service that functions as a "card", i.e. can be topped up, balance checked etc. Maybe using Google Wallet and similar services. * Explore options for partnering with ISPs and telecom operators such that using your phone as a bus card and searching for route information on ORC or Google Transit will not incur usage charges, or count against a quota. * Explore options for extending WiFi to more than the occasional experiment on a couple of buses. Obviously free would be preferable, but maybe access could be linked to use of the bus "card" on one's phone.